In forming Parts Inc. as a corporation, Candice transferred inventory to Parts Inc. in exchange for 30 percent of the corporation's stock (60 shares v
In forming Parts Inc. as a corporation, Candice transferred inventory to Parts Inc. in exchange for 30 percent of the corporation's stock (60 shares valued at $130,000). The inventory's fair market value was $147,000 and its tax basis to Candice was $75,000. The inventory was subject to a $17,000 liability that Parts Inc. assumed on the transfer. Candice borrowed the $17,000 from the bank (using the inventory as collateral) shortly before transferring the inventory to Parts Inc., and she used the loan proceeds to pay for a family vacation to Europe.
\r\na. Assuming the transfer qualifies under §351 and that the liability has a tax-avoidance purpose, what gain or loss will Candice recognize on the transfer?
\r\nb. Assuming the transfer qualifies under §351 and that the liability has a tax-avoidance purpose, what is Candice's basis in the stock she received in the exchange?
\r\nc. Suppose the liability does not have a tax-avoidance purpose. What gain will Candice recognize on the transfer?
\r\nd. Assuming the liability does not have a tax-avoidance purpose, what is Candice's basis in the stock she received in the exchange?
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